Using Customer Testimonials and Endorsements Legally: Rules for Ontario Businesses

A glowing customer quote on your homepage, a five-star review pinned to the top of your listing, an influencer holding up your product — testimonials and endorsements are some of the most persuasive marketing tools available to an Ontario business. They are also, legally, treated as advertising, which means the same misleading-advertising rules that apply to your headlines apply to the words you put in someone else's mouth.

Using testimonials and endorsements legally comes down to a simple underlying principle: the impression they create for a customer has to be genuine. Once you understand where the lines are, building a compliant review and endorsement program is straightforward.

The Core Rule: Testimonials Must Reflect a Genuine Experience

Displaying a testimonial is itself a representation to the public — you are telling potential customers "this is what a real customer thinks." That means:

• The testimonial should come from someone who genuinely used the product or service.
• It should not be edited in a way that changes its meaning (trimming a five-star review down to hide a caveat can be just as misleading as inventing a quote entirely).
• It should still reflect a current, accurate impression — a testimonial about a product that has since changed significantly can become misleading over time.

Fake and Manipulated Reviews

Reviews that do not come from a genuine customer experience raise the same concerns whether they were written entirely by staff, generated to inflate a star rating, or solicited in exchange for a discount without disclosure of that exchange. A pattern of manipulated reviews is treated as a form of misleading advertising, not a harmless marketing tactic.

This also cuts the other way: businesses generally should not suppress or selectively delete only negative reviews while leaving the impression that all feedback shown is representative, if that curation meaningfully distorts the overall picture a customer would form.

Paid and Incentivized Endorsements

When a business pays someone — cash, free product, an ongoing partnership — to promote it, that relationship is what regulators call a material connection, and it generally needs to be disclosed clearly enough that an ordinary person would notice and understand it before relying on the endorsement.

A disclosure that is technically present but buried, vague, or easy to miss (a single hashtag among twenty others, for example) may not do the job. The test again comes back to overall impression: would a reasonable person seeing this content understand that the person was compensated to say it?

Building a Compliant Testimonial and Endorsement Program

• [ ] Keep records of who gave each testimonial and confirm they actually used the product or service.
• [ ] Avoid editing quotes in ways that change their substance or omit important qualifiers.
• [ ] Refresh or retire testimonials that reference features, pricing, or claims that are no longer accurate.
• [ ] Disclose any payment, free product, discount, or ongoing relationship behind an endorsement — clearly and prominently, not buried in fine print.
• [ ] Set a policy for how your team collects, verifies, and displays reviews, so decisions are not made ad hoc by whoever manages the website.
• [ ] Train anyone managing social media or influencer relationships on disclosure requirements before campaigns launch.

Why Small Businesses Should Take This Seriously

It is tempting to assume these rules are aimed at large national brands, but the underlying misleading-advertising principles apply regardless of business size. A local service business that quietly writes its own five-star reviews, or that gives a customer a discount for a positive review without disclosing the exchange, is exposed to the same general framework as a much larger company — the enforcement priority may differ, but the legal standard does not.

Frequently asked questions